In the previous installment (Part VII) of this blog series on OSHA’s Top 10 most cited violations for fiscal year 2020, we looked at plastics and rubber manufacturing (NAICS 326), personal and laundry services (NAICS 812), the U.S. Postal Service (NAICS 491), and chemical manufacturing (NAICS 325).
Here, we’ll look at the top violations issued by OSHA in FY 2020 in these industries:
- Petroleum and coal products (NAICS 324)
- Food manufacturing (NAICS 311)
- Forestry and logging services (NAICS 113)
- Waste management and remediation services (NAICS 562)
As a reminder, OSHA in FY 2020 conducted only 21,680 inspections – one of the lowest totals on record and down from 33,401 in FY 2019. (Those totals are also down from 70,000-plus inspections per year in the 1980s.) Hence, the number of violations in FY 2020 is fewer than in FY 2019, but the most cited violations remain consistent.
For the petroleum and coal products manufacturing industry, 261 violations were issued, of which 193 were cited as serious. The Top 10 standards cited are:
| Rank | OSHA standard | No. of violations | Standard description |
|---|---|---|---|
| 1 | 1910.147(c)(4) | 15 | Lockout/Tagout – Lack of energy control procedures |
| 2 | 1910.119(j)(4) | 12 | Process Safety Management – Mechanical integrity, inspection and testing |
| 3 | 1910.119(d)(3) | 10 | PSM – Process safety information, information pertaining to the process and equipment |
| 4 | 1910.119(e)(3) | 7 | PSM – Process hazard analysis shall address the hazards of the process, engineering and administrative controls, consequences of controls failure, and facility siting |
| 5 | 1910.119(f)(1) | 6 | PSM – Failure to develop and implement operating procedures |
| 6 | 1910.1200(f)(6) | 5 | Hazard Communication – Workplace labeling |
| 1910.119(f)(4) | 5 | PSM – Operating procedures, failure to develop safe work practices | |
| 1910.119(h)(2) | 5 | PSM – Contractors, employer responsibilities | |
| 1910.132(d)(1) | 5 | Personal Protective Equipment – Failure to conduct a hazard assessment for PPE use | |
| General Duty Clause – Section 5(a)(1) of the OSH Act | 5 | General Duty Clause |
The top standouts for this group were dominated by Process Safety Management. In fact, of the total violations cited, 70 were tied to 1910.119, with 20 specific paragraphs of the standard cited. The General Duty Clause was in the Top 10 with five violations – no trends in the use of the clause were noted.
For the food manufacturing industry, a total of 2,723 violations were issued, of which 1,952 were cited as serious. The top 10 standards cited are:
| Rank | OSHA standard | No. of violations | Standard description |
|---|---|---|---|
| 1 | 1910.212(a)(1) | 205 | Machine Guarding – General machine guarding |
| 2 | 1910.147(c)(4) | 168 | Lockout/Tagout – Lack of written energy control procedures |
| 3 | 1910.147(c)(7) | 108 | Lockout/Tagout – Lack of training and education for employees |
| 4 | 1904.147(c)(6) | 80 | Lockout/Tagout – Failure to conduct periodic inspections |
| 5 | 1910.212(a)(3) | 78 | Machine Guarding – Failure to use point of operation guarding |
| 6 | General Duty Clause – Section 5(a)(1) of the OSH Act | 56 | General Duty Clause |
| 7 | 1910.147(d) | 46 | Lockout/Tagout – Failure to implement implementation procedures |
| 8 | 1910.1200(e)(1) | 43 | Hazard Communication – Lack of a written program |
| 9 | 1910.28(b)(1) | 40 | Fall Protection – Protection against unguarded/unprotected sides and edges greater than 4 feet above the lower surface |
| 10 | 1910.147(c)(1) | 35 | Lockout/Tagout – Lack of a written program |
The most frequent violations cited were related to the standard on lockout/tagout (1910.147). Also reaching into the Top 10 was the General Duty Clause, with 56 violations cited. Hazards cited under the clause (ranked from most to the fewest) included:
- Struck-by or caught-in
- Lockout/tagout
- Combustible dust
- Steam pressure hazards
- Fall hazards
- Amputation hazards
- Equipment overpressurization
- Chemical overexposures
- Explosion hazards
- Ergonomics
- Potential for an ammonia release
For the forestry and logging services, 78 total violations were issued, of which 48 were cited as serious. The top five violations cited included 1910.266(h)(2) for violations related to manual felling, with seven violations; 1910.266(i)(7) for a lack of first aid training, with five violations; 1910.266(d)(1) for PPE, with five violations; 1904.39(a)(2) for not reporting a hospitalization within 24 hours, with four violations; and 1910.266(f)(3) for equipment not provided with falling object protection, with four violations.
For the waste management and remediation services industry, 899 total violations were issued, of which 612 were cited as serious. The top standards cited are:
| Rank | OSHA standard | No. of violations | Standard description |
|---|---|---|---|
| 1 | General Duty Clause – Section 5(a)(1) of the OSH Act | 30 | General Duty Clause |
| 2 | 1910.1200(e)(1) | 23 | Hazard Communication – Lack of a written program |
| 3 | 1910.28(b)(1) | 22 | Fall Protection – Protection against unguarded/unprotected sides and edges greater than 4 feet above the lower surface |
| 4 | 1910.1200(h)(1) | 21 | Hazard Communication – Lack of or deficiencies in employee training |
| 5 | 1910.212(a)(1) | 17 | Machine Guarding – General machine guarding |
| 6 | 1910.134(e)(1) | 14 | Respiratory Protection – Failure to provide a medical evaluation |
| 7 | 1910.134(f)(2) | 13 | Respiratory Protection – Fit testing, failure to ensure an employee wearing a tight-fitting respirator is fit tested before initial use |
| 8 | 1910.147(c)(4) | 12 | Lockout/Tagout – Lack of written energy control procedures |
| 1910.178(l)(1) | 12 | Powered Industrial Trucks – Operator Training – Safe operation | |
| 10 | 1904.39(a)(2) | 10 | Failure to report a hospitalization within 24 hours |
| 1910.22(a)(1) | 10 | Housekeeping – Keeping all places of employment clean and sanitary | |
| 1910.146(d)(4) | 10 | Confined Spaces – Failure to provide necessary equipment specified in this section to entrants at no cost | |
| 1910.146(e)(1) | 10 | Confined Spaces – Permit system, before entry is authorized, the employer shall document the completion of measures required by section (d)(3) of this section | |
| 1910.132(d)(1) | 10 | Personal Protective Equipment – Failure to conduct a hazard assessment for PPE use |
The top cited violations in this industry centered on hazard communication, confined spaces, respiratory protection, lockout/tagout and the General Duty Clause. The top cited item was the General Duty Clause, cited 30 times. These violations were also tied to fatality and serious injury/illness reduction and (ranked from most to the fewest) included:
- Crushing/caught-in hazards
- Struck-by hazards
- Heat stress hazards
- Falls
- Lack of training
- Hazards related to fire and explosion
- Release of compressed gas
- Asbestos
- Electrical hazards
- Lack of a safety program
- PPE
Part IX of this series will include a final summary of the top violations for FY 2020.
This article represents the views of the author and should not be construed as a National Safety Council endorsement.
Richard Fairfax (CIH, retired 2017) joined OSHA in January 1978 and retired from the agency in 2013. At OSHA, he was a practicing field industrial hygienist, as well as the deputy director and director of enforcement programs. In 2008, Richard served as acting director of construction and, in 2010, was designated deputy assistant secretary – overseeing all field, enforcement and training operations. From 1993 through 2010, Richard wrote an industrial hygiene column entitled, “OSHA Compliance Issues” for the Journal of Occupational and Environmental Hygiene. He still serves on the Editorial Review Board. Richard now works part time for NSC-ORC HSE.
